Subject equivalence in academic appointments upheld where Political Science and Public Administration were treated as interchangeable disciplines.

SC considered whether a candidate with postgraduate and Ph.D. qualifications in Political Science was eligible for appointment as Reader in Public Administration. It read the qualification requirement in light of the expression "relevant subject" and held that the Regulations could not be construed to require an exact match of discipline where that would produce an absurd result. The Court treated the omission as supplied by necessary implication, accepted the academic view that Political Science and Public Administration are inter-related and interchangeable, and held that courts should defer to such expert opinion on subject equivalence. The appointment was upheld and the High Court's setting aside of the selection was reversed.

---

---

Issues: Whether a candidate holding a postgraduate degree and Ph.D. in Political Science was eligible for appointment as Reader in Public Administration, and whether the High Court was right in setting aside the appointment on the ground that the qualification had to be in the exact subject of Public Administration.

Analysis: The qualification requirement for Reader had to be read with the expression "in the relevant subject", even though those words were not expressly repeated in the Reader clause of the Regulations. A contrary reading would produce an absurd result by permitting appointment to a discipline wholly unrelated to the subject of study. The omission was treated as one that could be supplied by necessary implication, and the rule was read in a manner consistent with the scheme of the Regulations. The views of the University and the University Grants Commission supported the position that Political Science and Public Administration were inter-related and interchangeable subjects, and courts were expected to defer to such academic opinion in matters of subject equivalence. The earlier decision relied on by the High Court was held not to be binding as it proceeded on concession and contained no independent reasoning on the point.

Conclusion: The appellant was held eligible for appointment as Reader in Public Administration, and the High Court's judgment quashing the selection was set aside.

---